Curt Teich Foundation v. Commissioner
United States Tax Court
Petitioner Teich, Sr., donated $ 1.2 million so-called blue chip securities to foundation in June 1960. In July 1960, foundation purchased for $ 400 per share, or an aggregate of $ 1.14 million, shares of stock of the Teich family corporation, paying therefor out of the proceeds of the sale of the donated securities. Respondent stipulated that the fair market value of such shares was at least $ 400 per share.
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Petitioner Teich, Sr., donated $ 1.2 million so-called blue chip securities to foundation in June 1960. In July 1960, foundation purchased for $ 400 per share, or an aggregate of $ 1.14 million, shares of stock of the Teich family corporation, paying therefor out of the proceeds of the sale of the donated securities. Respondent stipulated that the fair market value of such shares was at least $ 400 per share. Foundation also accumulated income during the years 1959-62. In 1963, respondent retroactively revoked foundation's exemption. Held, that the 1960 transactions did not operate to deprive…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in income and gift taxes as follows:
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The issues for decision are:(1) Did respondent properly revoke, the exemption of Curt Teich Foundation for all or some of the years in question?(2) Did Curt Teich, Sr.’s gift of securities to the Curt Teich Foundation qualify as a deductible charitable contribution on his 1960 gift tax return?
FINDINGS OF FACT
•Some of the facts have been stipulated and are found accordingly. Curt Teich Foundation (hereinafter referred to as the foundation) was organized under the laws of Illinois as a general…
2Cases cited18 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- The Lesavoy Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
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3Cited by5 opinions
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- Ina Belle Thompson and B. D. White, Administrators of the Estate of I. W. Thompson v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969